Spill Prevention, Control, and Countermeasure Plans (SPCC’s) are required by the EPA when certain threshold amounts of stored oils are reached.  See: 40 CFR, Subchapter D, Part 112.7. We find that there are often flaws or omissions in SPCC plans. They include:

  1. Failing to include oils stored in stationary equipment such as hydraulic systems and/or crankcases.
  2. The SPCC Plan did not have a signature of approval by management (40 CFR 112.7)
  3. The SPCC Plan was not certified by a PE (40 CFR 112.3(d))
  4. No spill history was included in the FRP (40 CFR 112.20(f)(2(i)(F))
  5. No self-determination criteria form was included in the SPCC Plan (40 CFR 112.20)
  6. The Plan lacks written procedures for inspections and for maintaining inspection records for 3 years (40 CFR 112.7(e))
  7. Personnel are not properly instructed in spill prevention procedures (40 CFR 112.7(f))
  8. Spill prevention briefings are not conducted for operating personnel (40 CFR 112.7(f)(3))
  9. Inspections are not conducted as required (40 CFR 112.7(e))
  10. Facility security measures, including fencing, gates, and/or security guards, are not mentioned in the SPCC Plan (40 CFR 112.7(g)(1))

These are but a few common gaps. We’ll discuss SPCC’s in more detail in an upcoming post.

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